Burden of proof in claims for disability benefits

In labor cases, as in all cases which require the presentation and weighing of evidence, the basic rule is that the burden of evidence lies with the party who asserts the affirmative of an issue.[1] In particular, in a case of claims for disability benefits, the onus probandi falls on the seafarer as claimant to establish his claim with the right quantum of evidence; it cannot rest on speculations, presumptions or conjectures.[2] Such party has the burden of proving the said assertion with the quantum of evidence required by law which, in a case such as this of a claim for disability benefits arising from one's employment as a seafarer, is substantial evidence.[3] Substantial evidence is not one that establishes certainty beyond reasonable doubt, but only "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion," even if other minds, equally reasonable, might conceivably opine otherwise.[4] It is more than a mere scintilla of evidence.[5]

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[1] General Milling Corporation-Independent Labor Union v. General Milling Corporation, 667 Phil. 371, 393 (2011).

[2] Gabunas, Sr. v. Scanmar Maritime Services Inc., 653 Phil. 457, 466 (2010); Andrada v. Agemar Manning Agency Inc., supra note 46, at 601.

[3] Cootauco v. MMS Phil Maritime Services Inc., 629 Phil. 506, 519 (2010).

[4] Mitsubishi Motors Phils. Corp. v. Simon, 574 Phil. 687, 695 (2008).

[5] Id.